Section 1 - The London Plan – Introduction

1. Paragraph 1.1: What is the London Plan?

No comments

2. Paragraph 1.2: What years will the new London Plan cover?

Whilst there is no fixed legal limit on the length of time an SDS can cover, a longer timeframe (such as the 23 year period being proposed) may be acceptable, provided that it can be justified (e.g. realistic, evidence-based and aligned with the long-term vision for the area).

3. Paragraph 1.3: How many homes will it plan for?

The maths here don’t quite add up. Planning for a population rise of one million people over the period covered by the next plan (e.g. 23 years) works out to 43,478 additional people per year.  Why has the government told the Mayor that London needs 87,992 (net) new homes per year, and why does this appear to be distributed across only the first 10 years? The government’s ‘standard method’ of calculating ‘housing need’ is not based on projected population growth and therein lies the crux of the dilemma. It is neither accurate nor realistic.  The Mayor should be challenging the government’s housing need methodology and seeking a reduction in London’s target.  As things stand the requirement will see unsupportable growth in our existing neighbourhoods and the irrecoverable loss of large areas of precious green belt.

4. Paragraph 1.4: Viability and delivery

It is noted in this paragraph that “the next London Plan will not increase the overall burden of planning policy requirements on development under the current circumstances.”  The current London Plan policy requirements already fetters development, and therefore the ambition of the next London Plan should be to address this – to strike a balance between encouraging housing delivery and protecting matter of acknowledged importance.  The London Plan should also focus on strategic matters only and leave the London boroughs through their local plans to consider locally specific issues.

5. Paragraph 1.5: What is this document about?

No comments

6. Paragraph 1.6: Legal and procedural requirements

No comments

7. Paragraph 1.7: Integrated Impact Assessment (IIA)

No comments

8. Paragraph 1.8: Habitats Regulations Assessment (HRA)

No comments

9. Paragraph 1.9: Beyond London

More than just expressing a vague openness to joint working, the Mayor should proactively engage with the neighbouring authorities through joint strategic statements or memorandums of understanding.  Cross-boundary studies should be produced that realistically address housing pressures, and evidence published that demonstrates he has explored agreements with surrounding areas to accommodate some of London’s housing need.

10. Paragraph 1.10: Good growth objectives

It will be important not to undermine the sound principles set out in the Good Growth objectives, in particular GG2 Making the best use of land, which states that a design led approach should be applied to determine the optimum development capacity of sites and that the distinct and varied character of places should be valued and used as a catalyst from growth.

11. Paragraph 1.11: The key diagram

The DLR extension to Thamesmead and Abbey Wood should show the potential continuation to Belvedere, including a proposed alignment, and the Elizabeth Line should also show potential continuation through Bexley to Ebbsfleet/Northfleet.  Additional transport infrastructure in north Bexley in particular can support the delivery of a significant number of new homes.

Section 2 - Increasing London's housing supply

1. Section 2: Increasing London's housing supply

Again, if the population is only projected to grow by one million by the end of the plan period (2050) why does so much housing need to be built, and why only within the first 10 years of the plan period?  Why is the Mayor not challenging the government on its ‘standard method’ in determining ‘housing need’ and propose a methodology that is more accurate and realistic?

2. Section 2: Increasing London's housing supply

Is there any information you need to upload for example, maps or graphics?

No

3. Paragraph 2.1: A brownfield first approach

A brownfield first approach makes the best use of land within London’s urban extent although it is clear that, given the housing targets being imposed, this will not provide sufficient capacity to meet need.  Nevertheless, when pursuing this approach it will be important to remember the principles of GG2 ‘Making the best use of land’ when seeking to ‘optimise’ sites.  Also, ‘higher density’ should not be counted by the number of units as this will just encourage the development of studios and one bedroom flats, which will lead to overcrowding.

4. Paragraph 2.1: A brownfield first approach

Is there any information you need to upload for example, maps or graphics?

No

5. Paragraph 2.2: London's call for sites - LAND4LDN

As a London borough working with the Mayor on the LAND4LDN programme, there is a significant concern that there is still a good deal of inaccuracy in the system, with many sites being counted as providing future capacity actually already built out for new housing or being double counted (for example, a site allocation or SHLAA 2017 site that has planning permission).  Unsound evidence will lead to false assumptions and poor policy decisions.  The GLA must reflect local knowledge and expertise in evidence gathering.

6. Paragraph 2.2: London's call for sites - LAND4LDN

Is there any information you need to upload for example, maps or graphics?

No.

7. Paragraph 2.3: Opportunity Areas

It is extremely disappointing that NO future transport infrastructure appears to be planned for Bexley Riverside OA, meaning that there are no mechanisms in place to unlock the development capacity of this large, potential growth area.  It is also noted that the Abbey Wood and Thamesmead OA is now identified as ‘nascent’ even though the Mayor recently adopted a planning framework for this OA, the Elizabeth Line now terminates here, the DLR extension and Thamesmead Transit is proposed and developments are approved and getting built out – surely this OA is ‘ready to grow’ or even ‘underway.’

8. Paragraph 2.3: Opportunity Areas

Is there any information you need to upload for example, maps or graphics?

No.

9. Paragraph 2.4: Central Activities Zone

The protection of London’s viewing corridors needs to be strengthened as these are already being undermined.

10. Paragraph 2.4: Central Activities Zone

Is there any information you need to upload for example, maps or graphics?

No.

11. Paragraph 2.5: Town centres and high streets

Residential development above ground floor commercial town centre uses should be required.  Some commercial developers (e.g. Lidl and Aldi) are extremely reluctant to put flats above their stores as it does not fit with their formulaic approach to retail development.

12. Paragraph 2.5: Town centres and high streets

Is there any information you need to upload for example, maps or graphics?

No.

13. Paragraph 2.6: Industrial land

This approach could potentially work provided that the Mayor relies on local evidence produced by the London boroughs when they are preparing their local plans, as it is for the boroughs, as local planning authorities, to designate land uses on their local plan policies maps.

14. Paragraph 2.6: Industrial land

Is there any information you need to upload for example, maps or graphics?

No.

15. Paragraph 2.7: Wider urban and suburban London

The potential to densify existing suburban housing areas should not be over played.  They are often constrained by poor infrastructure which cannot be easily mitigated, leading to negative impacts for existing residents.  Densification also often results in poor quality supply that does not meet local housing need.  This is exemplified in Bexley through the emergence of a significant HMO issue which has seen growing clusters of provision critically undermining the supply of much needed family housing and raising hugely harmful environmental issues such as parking stress and cluttered and unsightly front gardens.
The suggestion that ‘low-density’ retail parks and car parks are ‘under-used sites’ jars with local evidence that shows these uses to be valued and necessary.  Not everyone is able to do their weekly shop and bring it home on the bus.  The loss of these uses will only work where public transport improvements are delivered first and in a meaningful way, in that it brings the site up to a reasonable public transport accessibility level.  Ideally, town centre sites would have commercial uses at ground floor, flats above, and enough car parking to ensure that the retail offer is attractive to customers, thus ensuring that the businesses remain viable.  Striking the right balance is essential in this context.

16. Paragraph 2.7: Wider urban and suburban London

Is there any information you need to upload for example, maps or graphics?

No.

17. Paragraph 2.8: Other sources of housing supply

It should be noted that the London Plan is not the vehicle for green belt release, and that the Mayor’s London-wide green belt review will need to be conducted in partnership with the London green belt boroughs.  It is for the London boroughs with designated green belts within their administrative areas to propose, and then make, changes to land use designations through the preparation and examination of their local plans.  London Borough of Bexley will be doing this with a view to protecting as much of its green belt land as government policy allows.  It is understood that the London Plan evidence base will require an understanding of potential release and capacities to inform housing targets, but this work must be undertaken in full cooperation with the relevant boroughs, using an agreed methodology and with a view to minimising the assumed release.

18. Paragraph 2.8: Other sources of housing supply

Is there any information you need to upload for example, maps or graphics?

No.

19. Paragraph 2.9: Beyond London's existing urban area

The statement that grey belt are areas of green belt that have either been previously developed or don’t’ strongly contribute to any of the three green belt purposes is incorrect.  Grey belt is defined in the NPPF glossary as “land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143.”  Therefore, previously developed land that is found to strongly contribute to any of the three green belt purposes does not meet the definition of grey belt.

It is extremely important that the Mayor works in partnership with the London green belt boroughs in defining grey belt in his London-wide green belt review as the boroughs will have local evidence with a finer-grained approach to its assessment within their administrative areas.  The borough intends to use this local evidence base to protect as much of this precious resource as possible.

20. Paragraph 2.9: Beyond London's existing urban area

Is there any information you need to upload for example, maps or graphics?

No.

21. Paragraph 2.10: Large-scale urban extensions in the green belt

It may be unrealistic to consider that large-scale (10,000+ homes) development opportunities can be delivered in the first 10 years of the plan period, which apparently is the only way they can count towards meeting the government’s requirement for London to deliver 88,000 new homes a year.  Would developers really keep to this schedule if it affects their profit margins?  As we know they phase the completion of units to ensure sale prices are maintained.

22. Paragraph 2.10: Large-scale urban extensions in the green belt

Is there any information you need to upload for example, maps or graphics?

No.

23. Paragraph 2.11: Metropolitan Open Land

It will be important to understand the criteria for MOL release.  For example golf courses that maintain openness with minimal structures can contribute to the purposes of MOL, which includes: providing green corridors, buffers and break in the built up area; offering visually open spaces that break up dense development; and, providing open air facilities for sport, recreation or leisure that are predominantly open in character.

24. Paragraph 2.11: Metropolitan Open Land

Is there any information you need to upload for example, maps or graphics?

No.

25. Paragraph 2.12: Affordable housing

Whilst  government funding decisions have had a major impact on the supply of genuinely affordable housing, there are other factors that have played a role in the low delivery rates of affordable housing.  Registered providers, who have a critical role to play in provision, have all but stopped their new development programmes in the light of urgent remediation requirements to existing stock following the Grenfell Inquiry and widely reported black mould issues.
Moreover, the emphasis on provision of new stock through private developments, secured by the planning system, means developers are allowed to negotiate down affordable housing obligations using viability assessments, in line with national and GLA policy, with negative consequences for supply.  Where supply is secured it is often the wrong sort of accommodation with the emphasis on unit numbers leading to an over provision of smaller flatted units.

26. Paragraph 2.12: Affordable housing

Is there any information you need to upload for example, maps or graphics?

No.

27. Paragraph 2.13: Planning for affordable housing

Mixed and balanced communities are essential to good growth.  As a result, a choice of housing products will be required to meet a range of needs.  As well as social housing, this should include low lost ownership and other initiatives to enable first time buyers to access the housing ladder.  It is agreed that land values need to reflect the policy position, but other development costs are also of relevance and influence viability, including volatile build cost inflation which often occurs after the land deal is done.

Moreover, the threshold approach does not provide a significant incentive in our experience.  Affordable housing levels are the single biggest challenge to development viability, far outweighing any costs associated with planning delays, particularly where such processes are being streamlined by other initiatives.  It is not considered that development in green belt necessarily offers an opportunity for enhanced affordable housing delivery, particularly where significant new infrastructure is required and hope value has increased.

28. Paragraph 2.13: Planning for affordable housing

Is there any information you need to upload for example, maps or graphics?

No.

29. Paragraph 2.14: Estate regeneration

We agree with the change to requiring full replacement of social rented homes in estate regeneration schemes even where there is no right to return provided such an approach does not undermine the overall regeneration objectives of the scheme.  The resulting unit sizes should however reflect the existing need profile.

30. Paragraph 2.14: Estate regeneration

Is there any information you need to upload for example, maps or graphics?

No.

31. Paragraph 2.15: Build to rent

The minimum requirement for 50 units for build to rent schemes could be reduced if this helps to secure delivery of this housing model; however at least 50% of the rented homes should be affordable and the development should be tenure blind.  Notwithstanding the above, experience suggests that such schemes do not provide appropriate units to meet local need whilst there are significant concerns over the regulation of the affordable element.

32. Paragraph 2.15: Build to rent

Is there any information you need to upload for example, maps or graphics?

No.

33. Paragraph 2.16: Other housing options

By focusing on rented accommodation and ensuring that 100% of the units are fully adaptable to meet disabled access standards means that there is less need for different types of specialist housing as the housing stock would be flexible and adapt to changes in London’s population.  This would be supported by lifetime neighbourhoods where people have a choice of accommodation to meet their different life stages within the same area or community.  This often preserves existing support networks, making people less dependent for longer.  However, this is increasingly undermined by the predominance of certain types of new supply such as smaller flatted accommodation and HMOs, which reduce the supply of other housing types and can lead to a range of amenity issues.  The new London Plan must take positive steps to safeguard against this.

34. Paragraph 2.16: Other housing options

Is there any information you need to upload for example, maps or graphics?

No.

35. Paragraph 2.17: Specialist and supported housing and housing London’s older population

It is appropriate for the London boroughs to set specialist and supported housing requirements in their local plans based on local evidence of need.  This is particularly important as this type of housing brings with it the additional costs of care, which are currently funded by the local authority.

36. Paragraph 2.17: Specialist and supported housing and housing London’s older population

Is there any information you need to upload for example, maps or graphics?

No.

37. Paragraph 2.18: Purpose-built student accommodation and other forms of shared housing

It is important for genuinely affordable rented housing to be as flexible as possible and purpose-built student accommodation or HMOs should be left to the London boroughs to consider in their local plans.

38. Paragraph 2.18: Purpose-built student accommodation and other forms of shared housing

Is there any information you need to upload for example, maps or graphics?

No.

39. Paragraph 2.19: Gypsies, Travellers and Travelling Showpeople

There are a number of London boroughs with up-to-date gypsy and traveller accommodation needs assessments that meet the government’s revised definition due to the Court of Appeal ruling.  The Mayor should work in partnership with the London boroughs in the preparation of a London-wide gypsy and traveller accommodation needs assessment, and it should be for the boroughs, through their local plans, to set housing requirements based on local assessments of need.

40. Paragraph 2.19: Gypsies, Travellers and Travelling Showpeople

Is there any information you need to upload for example, maps or graphics?

No.

Section 3 - Growing London's Economy

1. Section 3: Growing London's Economy

London’s key growth sectors identified in the London Growth Plan support the ambition for economic growth across town centres, opportunity areas and industrial locations that, as a consequence, ‘enables jobs, services, and business opportunities near to people’s homes.’  However, there is a potential conflict here with the proposal to shift industrial land out to the grey belt.  People should be able to access their workplace easily, and the Mayor still appears to support the principle of the 15-minute city.

An up-to-date strategic London Plan policy that acknowledges the flexibility of the E use class and of the permitted development right to convert to housing would be appropriate although detailed policy approaches should be a matter for the boroughs, including through the use of Article 4 Directions.

2. Section 3: Growing London's Economy

Is there any information you need to upload for example, maps or graphics?

No.

3. Paragraph 3.1: The Central Activities Zone

No comments.

4. Paragraph 3.1: The Central Activities Zone

Is there any information you need to upload for example, maps or graphics?

No.

5. Paragraph 3.2: Specialist clusters of economic activity

Care will need to be taken to ensure that the identification of ‘clusters’ of economic activity does not generate unacceptable adverse effects on the area being identified – for example, an industrial location where there are already a number of waste and recycling facilities would not benefit from further facilities being located there, due to the increased noise and air pollution that would be created.

In addition, identifying ‘clusters’ of specific types of economic activity could constrain the decision-making process at the local planning authority level, which will be looking for the best outcomes for local residents and businesses and could undermine the resilience of local economies to economic downturns and restructuring.  The London Plan must only deal with matters that are of ‘strategic importance’ to Greater London.

6. Paragraph 3.2: Specialist clusters of economic activity

Is there any information you need to upload for example, maps or graphics?

No.

7. Paragraph 3.3: Town centres and high streets

The London Plan does not need to address many of the points raised in the paragraphs of section 3.3.  The NPPF already has well-established policies on town centre uses, including a definition of ‘main town centre uses’ in the glossary.  Local authorities develop bespoke local planning policies, supported by evidence, to address local matters, including managing uses such as betting shops, pay day loan shops or hot food takeaways, or ensuring that social and community infrastructure and facilities are re-provided where the need has been identified.

Town centre hierarchies can be important in ensuring development of the appropriate nature and scale is directed to the right locations and that a good mix of different types of service centres are maintained.  If these are to be removed, the London Pan will need to ensure appropriate safeguards are maintained in this respect.

We are also concerned at the reference to linking the use of Article 4 Directions to the existence of a clear and positive route to housing delivery in town centres.

This is not an explicit requirement of pursuing an Article 4 Direction which primarily requires the demonstration of wholly unacceptable harm arising from the permitted development   Such a direction would also not prohibit housing delivery but simply put it under planning control with associated controls on the nature of development.

8. Paragraph 3.3: Town centres and high streets

Is there any information you need to upload for example, maps or graphics?

No.

9. Paragraph 3.4: Industrial Land

The NPPF encourages the identification and protection of suitable sites where justified.  Setting what industrial land needs to be protected for each borough and targets for industrial capacity in the London Plan is not appropriate.  The designation, or de-designation, of industrial land is a matter for local plans, which can assess and prioritise areas that best meet industrial need.  This can still be in general conformity with the London Plan, when supported by a clear local industrial land demand study, showing a surplus, and a demonstration of intensification elsewhere.  This allows the flexibility local authorities need to plan for growth in their area and contribute to the growth of London as a whole.

In terms of introducing more light industrial uses into town centres this is already possible as the activity lies within class E.  In terms of co-location, our experience is that the principle of no net loss of industrial floor space is challenging in industrial locations that are already relatively densely developed.  In addition, our experience is that co-location is often used to introduce new retail uses outside of town centre locations with compensatory ‘industrial’ floor area as self-storage with relatively low employment densities.

10. Paragraph 3.4: Industrial Land

Is there any information you need to upload for example, maps or graphics?

No.

11. Paragraph 3.5: London's night-time economy

The proposals seem sensible, as long as local impacts are managed.

12. Paragraph 3.5: London's night-time economy

Is there any information you need to upload for example, maps or graphics?

No.

13. Paragraph 3.6: Culture and creative industries

The agent of change principle is an important tool in ensuring that existing uses are protected from complaints from new residential development.  Whilst important not to repeat national policy, these uses need all the help and protection possible.  As more people move into town centres or on to locally significant industrial sites or adjacent to strategic industrial locations, tensions may escalate between residents and businesses.  and  it is likely that there will be evidence supporting a London-wide strategic approach.

14. Paragraph 3.6: Culture and creative industries

Is there any information you need to upload for example, maps or graphics?

No.

15. Paragraph 3.7: Visitor economy

Whilst the C5 use class for short-term let accommodations has not been implemented through an amendment to the Use Classes Order, a strategic London-wide policy could be useful.  In terms of the promotion of purpose built visitor accommodation, the plan should consider the implications of the use of these facilities as hostels for those in need of emergency accommodation and the implications this often has for the amenity of the relevant area.

16. Paragraph 3.7: Visitor economy

Is there any information you need to upload for example, maps or graphics?

No.

17. Paragraph 3.8: Digital infrastructure

It would be best for the London boroughs to consider, in their local plans, local implementation and coordination of digital infrastructure, as this will need local planning solutions in association with other local initiatives.  In addition, changes to the NPPF and the possibility of large-scale data centres being brought into the NSIP (Nationally Significant Infrastructure Projects) consenting regime means a London Plan policy approach may not be required.  Digital connectivity improvement is a key issue in the borough and the mayor should focus on supporting improvements through grant funding and other practical measures.

18. Paragraph 3.8: Digital infrastructure

Is there any information you need to upload for example, maps or graphics?

No.

19. Paragraph 3.9: Access to employment

Local plans provide policies for these matters, as education levels, types of under-represented groups and income levels are specific to a locality and local authorities are best placed to ensure that their residents benefit from the access to employment.  Nevertheless, some cross boundary brokering may be appropriate provided it is sensitive to local circumstances.

20. Paragraph 3.9: Access to employment

Is there any information you need to upload for example, maps or graphics?

No.

21. Paragraph 3.10: Affordable workspace

There is likely to be a reason that different London boroughs take very different approaches to affordable workspace, suggesting that a strategic London-wide approach would be inappropriate.  This matter is being addressed in local plans and should remain this way, given the significant variation in average income, depravation rates, etc. across London.

22. Paragraph 3.10: Affordable workspace

Is there any information you need to upload for example, maps or graphics?

No.

Section 4 - London's capacity for growth and design quality

1. Paragraph 4.1: Building height and scale

Densification needs to be applied cautiously as it  potentially comes at the cost of changing London’s overall character as well as increasing pressure on local infrastructure.  London's character partly lies in its contrast between dense urban cores and leafy, quiet outer districts.  These outer districts are not a homogenous mass but have their own intrinsic character based on topography, local land ownership, transport connections etc.  Uniform densification could lose this valuable diversity.

The right approach must be found that adds housing without erasing what makes London’s suburbs distinct and beloved.  Change will need to be managed carefully at a local level to ensure it is sustainable and support for growth among existing residents is maintained.

Design codes must be set by local planning authorities in their local plans, based on a deep understanding of local context and not in the spatial development strategy.  High density is not solely a function of greater height.  Rather than towers, density can come from other building types more in scale with their surroundings, such as townhouses, mansion blocks, or low-rise flats over shops.

2.    Paragraph 4.1: Building height and scale

Is there any information you need to upload for example, maps or graphics?

No.

3.    Paragraph 4.2: Tall Buildings

The Council is fundamentally opposed to the London Plan setting requirements for tall buildings.  These must be left exclusively in the purview of London boroughs to include in their local plans and local design guides.  Simply because some boroughs have not included such policies should not mean that all boroughs lose that control.  Where such an issue is so sensitive, it is not an appropriate solution to simply take local control away.  That would be a recipe for disaster.  Your discussion around the definition of clusters illustrates the point – defining a single threshold across London is patently ridiculous.  Boroughs will have more detailed evidence on local character and a more nuanced policy approach to the design of buildings that allows for an increase in density without drastically altering a neighbourhood’s feel.  It is also right that, even in an area identified as suitable for tall buildings, the buildings should still be assessed on their individual merits.

4.    Paragraph 4.2: Tall Buildings

Is there any information you need to upload for example, maps or graphics?

No.

5.    Paragraph 4.3: Supporting a denser London linked to transport connectivity

The London Plan should apply a more refined measure than PTAL to assess how well connected places are.  A high PTAL is not necessarily reflective of reality if the only choice is taking the bus, for example, which may not be as quick and efficient as people need it to be.  It is therefore encouraging to see that other metrics are being considered but at the same time very concerning that, to our knowledge, TfL has not engaged with boroughs in the development of this new measure.  Their workings should be shared with boroughs as soon as possible.

It is agreed that it is important to make better use of existing transport infrastructure – however, there are limits to this and some drawbacks.  For example, previous metroisation proposals have required a reduction in the number of central London termini available to commuters on some lines with resulting impacts on connectivity and choice.  Moreover, Bexley STILL has a very limited number of public transport mode options, with complete reliance on heavy rail and bus services.  This fundamentally undermines the borough’s ability to meet its full potential for growth and results in perverse outcomes.  For example, the ‘6a’ PTAL in Bexleyheath is solely achieved through bus services but the LAND4LDN programme suggests that, as a result, the density of new housing should be the same as in central London!  A change in methodology is necessary if a denser London is genuinely to be linked to transport connectivity.  (Please note that TfL defines PTAL as ‘public transport access level’ (tfl.gov.uk/info-for/open-data-users/our-open-data) not ‘accessibility’ level.)

6.    Paragraph 4.3: Supporting a denser London linked to transport connectivity

Is there any information you need to upload for example, maps or graphics?

No.

7.    Paragraph 4.4: London's heritage

For designated heritage assets, it would be appropriate for policies on adaptation and retrofitting to be set nationally and for Historic England to provide expert guidance and best practice.  Retrofitting historic buildings is complex, requiring specialist knowledge and interventions that are technically sound and culturally appropriate.  A London Plan policy supporting adaptation and retrofitting should take care not to risk over-prioritising these adaptations and as such potentially damaging the historic significance of the designated historic asset.

8.    Paragraph 4.4: London's heritage

Is there any information you need to upload for example, maps or graphics?

No.

9.    Paragraph 4.5: Designing the homes we need

We agree that good quality homes are what should be provided.  This requires appropriate planning controls and a properly resourced Local Authority Building Control.

10.    Paragraph 4.5: Designing the homes we need

Is there any information you need to upload for example, maps or graphics?

No.

11.    Paragraph 4.6: Heat risk, ventilation and overheating

Passive design is not precluded by the Building Regulations however mechanical solutions are often seen as cheaper and easier to implement by developers and therefore favoured.  Additional requirements through planning may have viability repercussions and may also make it harder for developers to meet other related building control requirements further down the track.  Any interventions will therefore need to be carefully considered for unintended consequences.

12.    Paragraph 4.6: Heat risk, ventilation and overheating

Is there any information you need to upload for example, maps or graphics?

No.

13.    Paragraph 4.7: Homes for families

Family sized housing (e.g. at least two double bedrooms), should always be provided in new developments, whether these are flats or houses.  Failing to provide family housing will just lead to overcrowding and other related adverse impacts.  A London-wide policy that protects the loss of family housing would be appropriate, as it is a key housing need.  Provision and retention are closely linked to social and community infrastructure requirements within the London boroughs, such as schools and places to play, and these should be planned for across London, even in high density areas, including their ongoing revenue needs.

14.    Paragraph 4.7: Homes for families

Is there any information you need to upload for example, maps or graphics?

No.

15.    Paragraph 4.8: Accessible housing

It would be useful for the London Plan to include a London-wide policy for barrier free design, which should be the standard for all new development, irrespective of tenure.  Applying the principles of ‘lifetime homes’ accommodates people as their needs change.  However, the approach should be applied flexibly to allow for site constraints (where these can be demonstrated).

16.    Paragraph 4.8: Accessible housing

Is there any information you need to upload for example, maps or graphics?

No.

17.    Paragraph 4.9: Space standards and other requirements

Yes, we would agree with the London Plan approach in this regard – the requirement for private outside space of a useful size is particularly appropriate.

18.    Paragraph 4.9: Space standards and other requirements

Is there any information you need to upload for example, maps or graphics?

No.

19.    Paragraph 4.10: Designing for everyone

Barrier-free should be the norm for all buildings, irrespective of use.  Designing with accessibility in mind from the start avoids legal risk and demonstrates social responsibility.  Barrier-free design improves the overall usability and quality of spaces for everyone – not just people with disabilities.  These approaches are well developed at the local level through local plan policies, supplementary planning documents and other tools such as design review panels.  A London Plan policy on this matter should not just be for large planning applications and residential development.  A universal design approach should be adopted with accessibility and inclusivity as standard, not an exception.  This aligns with global best practices in sustainable and inclusive urban development.

20.    Paragraph 4.10: Designing for everyone

Is there any information you need to upload for example, maps or graphics?

No.

Section 5 - London's infrastructure, climate change and resilience

1.    Section 5: London's infrastructure, climate change and resilience

Infrastructure is critical to good growth and appropriate investment must go hand in hand with development.  Where development viability is more challenging, such as in places like Bexley, other sources of funding will be required, including national and mayoral investment whilst additional local funding sources could also be explored.  The UK has a binding target for climate change and zero carbon in new development is already a local plan requirement.  The London Plan policy approach should be to continue to set the bar in order to achieve what is necessary in the timeframe we have to meet net zero.

2.    Section 5: London's infrastructure, climate change and resilience

Is there any information you need to upload for example, maps or graphics?

No.

3.    Paragraph 5.1: Energy efficiency standards

The effectiveness of using carbon offsetting in reducing overall emissions is highly contested.  Energy use is a direct, on-site activity.  Offsetting doesn’t change building design, material choices, or energy efficiency measures.  Offsetting does not reduce energy use, and it should not be a substitute for real, on-site carbon and energy reductions.  The London Plan policy approach should be to focus on real reductions by requiring new buildings to be designed to zero carbon measures.  As a last resort, offsetting could be justified only for the small percentage of emissions that are genuinely hard to eliminate with current technology, and when paired with a strong, enforced ‘fabric first’ and energy efficiency hierarchy.  There should also be more consideration of the potential to further encourage retrofitting in existing stock in circumstances where the planning system has a role.

4.    Paragraph 5.1: Energy efficiency standards

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No.

5.    Paragraph 5.2: Heat networks

We would welcome a direct requirement for waste heat to be made available for new networks or to support decarbonisation of existing networks, in order to optimise this energy source.  This should be for all waste heat emitters, whether existing or proposed.  However, we would also point out that these initiatives will only come forward if they become more affordable.  Heat network operators often form local monopolies and consumer protection has suffered as a result.  A joined-up approach is therefore required to ensure such networks are fair and sustainable.

6.    Paragraph 5.2: Heat networks

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No.

7.    Paragraph 5.3: Whole life-cycle carbon (WLC) and Circular Economy (CE)

Current London Plan WLC and circular economy policies represent progressive thinking by shifting the focus from operation energy to embodied carbon and resource use.  However, they are mostly reporting requirements, not performance standards, meaning compliance does not actually offer significant reductions.  In addition, many planning authorities lack the experience to scrutinise WLC assessments in detail and actual carbon impact can vary significantly from what’s modelled in any case.  A London Plan policy on this matter will need more ‘teeth’ to be effective: setting mandatory performance targets and enforcement mechanisms; and be linked to investment in reuse infrastructure and better planning authority training and tools.  In terms of the retention of existing structures, there would appear to be a tension between intensification of industrial activity to optimise site usage and the reuse of older industrial premises that were designed to accommodate different industrial processes and workflows.

8.    Paragraph 5.3: Whole life-cycle carbon (WLC) and Circular Economy (CE)

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No.

9.    Paragraph 5.4: Waste

A new London Plan policy on borough-level waste apportionment targets will need to be based on an agreed methodology with the London boroughs.  Self-sufficiency should be across smaller, sub-regional groupings, not London-wide, as this undermines the proximity principle.  A London-wide approach may mean only several boroughs carrying the waste capacity for the entire region, which will have significant environmental impacts both at the waste management facility and through getting waste to the facility for processing (particularly as waste lorries transport much of London’s waste).  There are unitary waste authorities and combined waste authorities (including four statutory joint waste authorities) across London and waste apportionments, directly linked to waste arisings in these areas, should be addressed at this level.

As well as waste apportionment issues it will be important the London Plan supports local efforts to improve waste management facilities in new developments, particularly higher density flatted schemes.  Local scrutiny has identified the provision, maintenance and management of effective waste facilities in such circumstances to be problematic, leading to environmental issues and poor recycling rates.

10.    Paragraph 5.4: Waste

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No

11.    Paragraph 5.5: Green and open spaces

It is interesting to note the map provided at figure 5.1 illustrates that much of London’s green cover comes from green belt land.  This identifies a tension between ensuring that London can address problems such as air pollution and biodiversity loss and at the same time propose green belt release has a role in meeting development needs.  The Environment Act 2021 introduced a strengthened biodiversity duty that requires all public authorities in England to consider what they can do to conserve and enhance biodiversity.  Given the tensions noted above, identifying realistic policies and specific objectives within the new London Plan will be an important consideration.

As a supporting authority, London Borough of Bexley has worked collaboratively with the GLA on the production of the London Local Nature Recovery Strategy, which will inform London-wide approaches to biodiversity and the definition of areas of strategic significance in the context of Biodiversity Net Gain.  However, borough-level biodiversity studies will have a crucial role to play in providing locally specific and detailed information for local plans.  Where these studies are published following the adoption of the LNRS and LGIF, they will provide more up to date, local evidence.

12.    Paragraph 5.5: Green and open spaces

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No.

13.    Paragraph 5.6: London's open spaces

There appears to be a significant amount of work duplication here.  The London boroughs, in their green infrastructure studies, already assess the quality, use and level of demand of green infrastructure, to understand and mitigate areas of open space deficiency.  Therefore, it should be for the boroughs, in their local plans, to designate open spaces and provide policies that address open space deficiencies.  In terms of MOL, its separation from the approach to green belt land is supported given its distinct role in London.

14.    Paragraph 5.6: London's open spaces

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No.

15.    Paragraph 5.7: Green infrastructure and biodiversity

The Bexley Local Plan policy that sets urban greening factor (UGF) requirements goes further than those stated within the London Plan by not excluding UGF for B2 and B8 uses.  All new developments are required to quantify the measures that have been taken to achieve urban greening on site.  All major developments are required to demonstrate what UGF score has been achieved, with proposals aiming to reach a score of at least 0.4 for residential developments and 0.3 for major mixed-use or commercial schemes.  Whilst it can be difficult to achieve the minimum target on some sites, the presence of a target itself is enough to motivate and encourage developers to consider appropriate forms of greening across all types of development.  A more comprehensive London Plan policy, similar to the Bexley Local Plan policy, would be useful.

16.    Paragraph 5.7: Green infrastructure and biodiversity

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No.

17.    Paragraph 5.8: Water

The risks highlighted from the London Climate Resilience Review should be incorporated into strategic London Plan policies particularly on large new developments in areas identified as having problems with urban drainage and sewer capacity.  Large scale development proposals, which may have been refused by local planning authorities due to lack of capacity and that it has not been possible to resolved should not then be called in by the Mayor to approve.  The London Plan should set clear policy expectations, including the use of planning conditions to secure delivery of environmental measures and standardised planning obligations that trigger enforcement if breached.  This gives the borough planning authorities a clear mandate to hold developers accountable at the application and post-construction stages.

18.    Paragraph 5.8: Water

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No.

19.    Paragraph 5.9: The strategic importance of London's waterways

The Joint Thames Strategies will be useful as a coordinated approach for the riparian London boroughs, and the Council is working in partnership with Thames Estuary Partnership in the refresh of the Thames Strategy East.  The NPPF and the current London Plan require local planning authorities to take a strategic approach to managing flood risk, enhancing biodiversity and shaping high-quality riverside development, and as such, a riverside strategy approach including specific requirements for new developments is already embedded in Bexley Local Plan policies.

20.    Paragraph 5.9: The strategic importance of London's waterways

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No.

21.    Paragraph 5.10: Flood risk management

Yes, we would agree that a London Plan policy requirement for new development to achieve greenfield runoff rates would be useful as a strategic, London-wide policy.  The policy could allow for exceptions, which the London boroughs could decide on at a local level based on their strategic flood risk assessments and include in local plan policies.  This would allow development to be permitted if the exceptions are robustly justified by the developer.

22.    Paragraph 5.10: Flood risk management

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No.

23.    Paragraph 5.11: Water management

When considering current policies in the London Plan that address water management, there appears to be a lack of clarity about whether a development proposal can be refused if there is no sewer capacity (e.g. the ‘last resort’ part of the drainage hierarchy).  The real world consequences of the critical importance of drainage capacity as part of sustainable water management is not explicitly clear, and this means it often falls to the Environment Agency or Thames Water to raise the matter when reviewing the development proposal.  This can lead to an underestimation of the risks during early-stage planning.
The current London Plan relies on Thames Water to identify the most appropriate strategy for ensuring that London’s drainage and wastewater systems can meet the needs of London in their London 2100 Plan.  However, if the existing sewer capacity is lacking and the drainage hierarchy is exhausted, the viability of a development itself may be threatened — unless the design incorporates robust, on-site water management.  If a new London Plan policy is to take a truly catchment-based approach to water policy, then it may be useful to identify those catchments that have reached breaking point, in order to focus funding for infrastructure upgrades in these areas.

24.    Paragraph 5.11: Water management

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No.

25.    Paragraph 5.12: Transport's role in London's growth

The Council is particularly concerned about the continuing imbalance in the availability of high quality, high frequency public transport access across parts of London and the seeming lack of acknowledgement of the importance of ensuring the road network is fit for purpose.  Our borough in particular is considered to suffer from a lack of public transport connectivity, being one of only two boroughs solely reliant on heavy rail and bus services for public transport provision.  It is also particularly dependent on an efficient and effective road network to serve our industrial areas and enable residents to access dispersed local services.
Bexley  is continually overlooked by the Mayor in the development of new transport infrastructure to support growth with the Elizabeth Line and the proposed Thamesmead Transit and DLR extensions all stopping on or just short of its western border with Greenwich.  Key road junctions are also left to clog up for want of capacity improvements that would enable economic development and housing growth as well as avoiding congestion and poor air quality.  This means that the Bexley Riverside Opportunity Area, with all its growth potential, remains nascent, whilst the much larger growth corridor between Abbey Wood and Ebbsfleet also remains unrealised.  Until the borough benefits from substantive transport improvements it will not be able to meaningfully contribute to the sustainable growth of London.

26.    Paragraph 5.12: Transport's role in London's growth

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No.

27.    Paragraph 5.13: Sustainable transport networks to support

London Borough of Bexley actively promotes the principles of healthy streets where appropriate on its highway network as set out in its Local Implementation Plan.  However, the lack of public transport options and the dispersed nature of key public services means that many residents have no realistic alternative to the car.  Prioritising measures that make car use more difficult could lead to significant adverse impacts particularly to older people, parents with young children, key workers and small businesses.  The London Plan must allow meaningfully for these local constraints when considering the role of transport networks in supporting growth.

28.    Paragraph 5.13: Sustainable transport networks to support

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No.

29.    Paragraph 5.14: Car parking, cycle parking and deliveries

The further expansion of car free or car lite approaches beyond current areas of focus is considered to be wholly inappropriate.  High car reliance in many low accessibility areas means such an approach is unrealistic and could lead to significant adverse effects.  Experience in Bexley clearly shows that reduced car parking in new developments does not lead to reduced car ownership.  As a result, residents seek to park their car on street with resulting adverse impacts on residential amenity and road safety with a knock on effect on the uptake of active travel in these areas.  The expanded use of kerb side parking controls to counter this is impractical as it is subject to separate legislation from the planning system, is hugely unpopular with existing residents who object to proposals and, if they are approved, often just shift the problem to the new boundary.  Our research also suggests that lack of appropriate parking in new developments in certain areas undermines their saleability with developers much preferring to provide an appropriate level of parking, particularly for family housing.

30.    Paragraph 5.14: Car parking, cycle parking and deliveries

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No.

31.    Paragraph 5.15: Responding to transport trends and new technologies

The Council is supportive of appropriate new technology to improve the efficiency of existing transport networks provided they are fair, safe, secure resilient, adequately developed and do not result in unforeseen consequences that outweigh any benefits.  For example, the use of road charging technology is clearly inappropriate at this stage given the degree of inequality in public transport provision across London, the current state of development of the technology and concerns regarding privacy.  However, ibus, real time journey information provides significant benefits to passengers and the installation of countdown boards are supported across the network.

32.    Paragraph 5.15: Responding to transport trends and new technologies

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No.

33.    Paragraph 5.16: Fire safety

Given that Building Regulations on fire safety are still in a state of flux and that they will only ever provide a minimum requirement, the principle of additional requirements through planning would appear reasonable provided that they can remain relevant through the period of change and they can be reasonably enforced through the planning process.

34.    Paragraph 5.16: Fire safety

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No.

35.    Paragraph 5.17: Air quality

Addressing air quality requires systemic change across a range of areas including construction, heating, and behaviour — as well as sustained policy leadership and enforcement.  Road transport is only one contributor to this issue and ongoing improvements, such as the electrification of the vehicle fleet will steadily reduce its impact.  Singling out transport in the efforts to improve air quality in London is therefore strongly opposed by the borough.  Some areas, particularly in outer London remain heavily reliant on road transport due to low public transport accessibility and the cost of moving to zero emission vehicles for some lower income households and small businesses.  The Mayor’s insistence on recently pushing through the expansion of the Ultra Low Emissions Zone despite significant local opposition is therefore considered wholly inappropriate and any further efforts to compound the error through the London Plan will be strongly resisted.  A far more balanced approach to tackling this issue is needed to ensure any benefits associated with clean air initiatives are not outweighed by associated negative impacts.

36.    Paragraph 5.17: Air quality

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No.

37. Paragraph 5.18: Heat risk

Tree cover is one of the best ways to address UHI.  In addition to borough-level green infrastructure strategies, developers should be encouraged to produce specific Tree Strategies for their developments, which should include climate resilient features such as larger and connected tree pits.  Given that newly planted trees are susceptible to climatic extremes a retention first approach as featured within the existing London Plan should be required, with more protection for existing mature trees including street trees such as London Planes.  The London Plane tree helps with air quality and urban heating, but as a deciduous tree with a broad canopy needs time to grow to maturity.  A policy approach will, therefore, be needed that requires developers to ensure that newly planted trees in their developments stand the test of time through long-term management.

38. Paragraph 5.18: Heat risk

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No.

39. Paragraph 5.19: Healthy communities

It is possible to provide policy protection for existing social and community infrastructure.  While some community facilities may fall under Use Class E, health and care facilities and crisis-support spaces often fall outside it, depending on the nature of their services.  Hospitals, residential care homes, mental health crisis centres or refuges, drug or alcohol treatment centres, community centres, food banks or youth centres, and emergency accommodate are all not typically under Use Class E.  Whilst the London Plan could provide a strategic policy on the matter, it should be for the London boroughs in their local plans to provide a level of detail based on local social and community assessments carried out for their infrastructure delivery plans (and as such linked to planning obligations and/or borough CIL spending).  The Mayor may be better consider how he could secure additional revenue funding to sustain existing services in London, as new and existing physical infrastructure often suffers from underuse and declining maintenance in the medium and long term.

40. Paragraph 5.19: Healthy communities

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No.